I don't think whatever is freely available from other sources effects fair use, though. If an article reviewed part of a short story, and printed two paragraphs, that wouldn't mean an article in a completely different journal couldn't print three completely different paragraphs from the same story.
If there were multiple articles in the same journal printing enough of the short story that you wouldn't even need to read it... sure. But what one person does with fair use doesn't effect unrelated uses.